beginning balance

L1: beginning balanceCould someone please provide insight as to why the total account value for the annuity method “should” be based upon the previous year end balance when calculating all future payments. The most current end of month balance as I understand it “can” be used to calculate the initial payment. Is there a IRS precedent/ruling that prohibits using the most current balance for all payments going forward? My SEPP guidebook basicaly states that the decision to use the year end balance or the most current balance is a no-guidance-provided-by-the-IRS area that should best be determined solely by a private letter ruling.Any help here most appreciated. And thanks in advance.2002-03-05 22:50, By: endgame, IP: [127.0.0.1]
L2: RE: beginning balanceI don’t know what “guidebook” you are using; however, the IRS has issued numerous (at least a dozen or more) PLRs where a taxpayer has chosen to commence SEPPs using a beginning account balance other than 12/31/XX. It is true that there are no rules or regulations on this issue as it has always been considered “too tactical” of an issue. However, the preponderance of evidence on this issue is your favor & you should feel comfortable selecting whatever month-end valuation daet suits your needs.TheBadger2002-03-06 07:53, By: TheBadger, IP: [127.0.0.1]

L2: RE: beginning balanceIn PLR 200105066, the IRS allowed updating the account balance annually as of the previous 12/31. Using the previous 12/31 balance probably originates from the date used to determine Required Minimum Distributions. If you are looking to use the balance of the previous month for each month going forward, you probably should get your own PLR.If you are going to used updated annual account balances, you should probably also annually recalculate the interest rate and mortality factor.2002-03-06 08:13, By: Gfw, IP: [127.0.0.1]